Appeals against administrative dispositions
Online Posting of Lodging Rate Tables: Suspension Standards for Missing Rates or Overcharging on Booking Apps and How to Respond
Under the Enforcement Rule of the Public Health Control Act as amended and effective on July 14, 2026, a lodging operator that uses an online interface such as a booking app or its own booking page for its lodging business must post its lodging rate table not only at the front desk but also on the online interface, and must comply with the posted rates (Annex 4, Item 1(d)(1) of the Rule). Failing to post the rate table online or charging more than the posted rate leads to a business suspension of 5 days for a 1st violation, 10 days for a 2nd, 20 days for a 3rd, and a business closure order for a 4th or subsequent violation (Annex 7, Part II, Item 1(d)5) of the Rule). However, violations caused by reasons for which the operator is not responsible, such as computer errors, are excluded.
Procedure
- Appeal Difficulty High
Submitting an opinion, objection or administrative appeal against a disposition or decision already made, or applying for damage relief or dispute mediation. The reviewing body decides after examining the facts and the law, so preparing supporting evidence is important.
We will prepare written opinions for prior notice of business suspension and fines, documents for hearing, and documents for administrative appeal and suspension of execution after disposition according to the selected procedure. Attendance and statements are not included in the written hearing.
Scope & fee
- Pre-disposition advance notice response statement: prepare and file
- We will review the prior notice and proof provided by 1 business location and prepare an opinion submission form. Attendance at the hearing and administrative review after disposition are separate. Scope of writing: 1 type of opinion submission, 5 pages per type. It does not include in-office submissions.
- Prepare written hearing submission; attendance excluded
- We will prepare hearing opinions, statement summaries, and supporting evidence for 1 hearing notice. The same prior notice opinion form will not be written repeatedly and hearing attendance and statements will not be included. Scope of writing: 1 type of hearing opinion/summary of statement, 5 pages per piece. It does not include in-office submissions.
- Official fee source ↗
- Post-disposition administrative appeal merits petition; stay of execution excluded
- We will prepare a claim for the merits of 1 case of business suspension, fine, etc. It does not include written opinions/hearings and suspension of execution before disposition. Scope of writing: 1 type of illegal/unfair disposition and reasons for requesting a reduction, 5 pages per type. It does not include in-office submissions.
- Official fee source ↗
- File administrative appeal after disposition and request stay of execution
- We will prepare the merits of an administrative appeal for 1 business disposition and an application for suspension of execution. Advance notice opinions, hearing documents, and hearing attendance are separate. It does not include in-office submissions.
- Official fee source ↗
- Stay-of-execution documents for an existing business disposition administrative appeal
- We will prepare an application for suspension of execution using records of business disposition administrative appeals that have already been filed and emergency damage data. It does not include new merits and independent motions without merits. Scope of writing: Reasons for application for suspension of execution Type 1, 3 pages per type. It does not include in-office submissions.
- Official fee source ↗
1. Check that front-desk and online rate tables match
Compare the rate table posted at the front desk with the rates posted on booking apps and your own booking page for each room type. An online interface means software such as a website or mobile app serving as an intermediary between consumers and businesses (Article 21-2(1) of the Act on the Consumer Protection in Electronic Commerce), so check whether the rate table is posted and what rates are actually charged on every booking channel used for the business.
2. Review the prior notice or hearing notice
The mayor, county governor, or district head must hold a hearing before ordering a business suspension or closure (Article 12 of the Public Health Control Act), and gives prior notice of the facts, the intended disposition, and the deadline for opinions or the hearing date (Article 21 of the Administrative Procedures Act). First check the violation date, applicable provisions, violation count, and opinion deadline in the notice, and if the violation date is before July 14, 2026, check whether the former sanction standards should apply.
3. Prepare the written opinion and evidence
If the violation was caused by reasons for which the operator is not responsible, such as a computer error or a delay in the booking platform reflecting rate changes, argue that it falls under the exclusion, and if the violation is minor, request a reduction of up to one half of the standard suspension days (Annex 7, Part I, Item 5 of the Enforcement Rule of the Public Health Control Act). Attach rate setting screens, platform change history, refund records, and photos of the corrected rate table, and submit them by the deadline (Article 27 of the Administrative Procedures Act).
4. Consider a penalty surcharge in lieu of suspension
Where a business suspension would cause serious inconvenience to users or otherwise harm the public interest, the mayor, county governor, or district head may impose a penalty surcharge of up to 100,000,000 won in lieu of the suspension (Article 11-2(1) of the Public Health Control Act). Because the surcharge is calculated by applying the standards in Annex 1 of the Enforcement Decree to the suspension period (Article 7-2 of the Enforcement Decree of the same Act), include the circumstances supporting a surcharge in your written opinion.
5. File an administrative appeal and request a stay of execution
Once the disposition is issued, an administrative appeal must be filed within 90 days from the date you became aware of it and within 180 days from the date of the disposition (Article 27(1) and (3) of the Administrative Appeals Act). Filing an appeal alone does not stop the suspension, so if the suspension start date is near, submit an application for a stay of execution at the same time (Article 30(1) and (2) of the same Act).
Required documents
- Written opinion (Attached Form No. 11 of the Enforcement Rule of the Administrative Procedures Act)
- Copy of the prior notice or hearing notice, and the business suspension disposition
- Copy of the lodging business report certificate
- Photos of the front-desk rate table and screenshots of the rates posted on booking apps and your own booking page
- Booking platform rate setting change history and computer error records (if applicable)
- Refund records for overcharged amounts and photos of the corrected rate table posting
- Administrative appeal petition (Attached Form No. 30 of the Enforcement Rule of the Administrative Appeals Act) and application for a stay of execution (Attached Form No. 33 of the same Rule)
- Letter of authorization (when entrusting preparation and submission of documents)
Fees
No statutory fee applies to submitting an opinion or filing an administrative appeal. Our office fee starts from the amount shown above and may vary depending on the stage of the disposition, the violation count, and the volume of evidence; we will give you an exact quote after reviewing your documents.
Legal basis and review date
- Enforcement Rule of the Public Health Control Act, Annex 4
- Enforcement Rule of the Public Health Control Act, Annex 7
- Enforcement Rule of the Public Health Control Act, Addenda (Ordinance No. 1186), Article 2
- Public Health Control Act, Article 4
- Public Health Control Act, Article 11
- Public Health Control Act, Article 11-2
- Public Health Control Act, Article 12
- Enforcement Decree of the Public Health Control Act, Article 7-2
- Act on the Consumer Protection in Electronic Commerce, Article 21-2
- Administrative Procedures Act, Article 21
- Administrative Procedures Act, Article 27
- Administrative Appeals Act, Article 27
- Administrative Appeals Act, Article 30
Check these first
- The violation count is based on sanctions received for the same violation within the most recent 1 year, so if you have prior sanctions, compare the prior disposition date with the date the new violation was detected to check that the count was applied correctly (Annex 7, Part I, Item 3 of the Enforcement Rule of the Public Health Control Act).
- When preparing a lodging business report, prepare the same rate table for the front desk and for booking channels from the start, and note that operating during a suspension period may lead to a business closure order (Article 11(3) of the Public Health Control Act).
Frequently asked questions
Do I need to post a rate table online if I operate only through booking apps?
What is the sanction for not posting the rate table online?
Will I be sanctioned if a platform computer error displayed the wrong rate?
Do the stricter standards apply to violations before July 14, 2026?
Can I entrust the response to a lodging business suspension to an administrative agent?
Contact us
Hwang Yunsang Administrative Office in Songdo, Incheon prepares and submits administrative documents and explains the procedure. If your situation is similar, send us a message.
📍 2697, 26F POSCO Tower-Songdo, 165 Convensia-daero, Yeonsu-gu, Incheon, Republic of Korea · 📞 010-3374-2687 · 🌐 hwangadmin.com
This guide is general information based on public sources. Requirements, documents and deadlines differ by case and by the competent agency, so please confirm them before you proceed.